FOURTH FIVE-YEAR REVIEW REPORT
BEAUNIT CORPORATION SUPERFUND SITE
GREENVILLE COUNTY, SOUTH CAROLINA
rtto sr4
<
30
\
w
PRO"**"
T>
z
ui
o
September 2018
Prepared for
U.S. Environmental Protection Agency
Region 4
Atlanta, Georgia
-------
Table of Contents
LIST OF ABBREVIATIONS & ACRONYMS iv
I. INTRODUCTION 1
Site Background 1
FIVE-YEAR REVIEW SUMMARY FORM .. 2
II. RESPONSE ACTION SUMMARY ; 5
Basis for Taking Action 5
Response Actions . 5
Status of Implementation 7
IC Summary Table 10
III. PROGRESS SINCE THE LAST REVIEW 12
IV. FIVE-YEAR REVIEW PROCESS 12
Community Notification, Involvement & Site Interviews 12
Data Review 13
Site Inspection 17
V. TECHNICAL ASSESSMENT 17
QUESTION A: Is the remedy functioning as intended by the decision documents? 17
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the
time of the remedy selection still valid? 18
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? 19
VI. ISSUES/RECOMMENDATIONS 20
VII. PROTECTIVENESS STATEMENT 20
VIII. NEXT REVIEW 20
APPENDIX A - REFERENCE LIST A-l
APPENDIX B - CURRENT SITE STATUS B-l
APPENDIX C - PRESS NOTICE C-l
APPENDIX D - SITE INSPECTION CHECKLIST D-l
APPENDIX E- INTERVIEW FORMS E-l
APPENDIX F - DETAILED ARARs REVIEW F-l
APPENDIX G - TOXICITY REVIEW G-1
ii
-------
Tables
Table 1: COCs by Media 5
Table 2: Surface Soil Cleanup Goals 6
Table 3: Groundwater Cleanup Goals 7
Table 4: Summary of Groundwater Monitoring Wells 9
Table 5: Summary of Planned and/or Implemented Institutional Controls 10
Table 6: Protectiveness Determinations/Statements from 2013 FYR 12
Table 7: Status of Recommendations from 2013 FYR 12
Table 8: Summary of Analytical Results and Field Measurements 16
Figures
Figure 1 - General Site Location Map 3
Figure 2 - Site Location Map 4
Figure 3 - Institutional Controls Base Map 11
Figure 4 - Groundwater Monitoring Results 15
iii
-------
LIST OF ABBREVIATIONS & ACRONYMS
AOC
Administrative Order on Consent
ARAR
Applicable or Relevant and Appropriate Requirement
BRA
Baseline Risk Assessment
CERCLA
Comprehensive Environmental Response, Compensation and Liability Act
CFR
Code of Federal Regulations
CIC
Community Involvement Coordinator
COC
Contaminant of Concern
DO
Dissolved Oxygen
EPA
United States Environmental Protection Agency
FYR
Five-Year Review
IC
Institutional Control
LOQ
Limit of Quantitation
MCL
Maximum Contaminant Level
MDL
Method Detection Limit
mg/kg
Milligrams per Kilogram
Hg/kg
Micrograms per Kilogram
Hg/L
Micrograms per Liter
MNA
Monitored Natural Attenuation
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
NPL
National Priorities List
O&M
Operation and Maintenance
OU
Operable Unit
PCB
Polychlorinated Biphenyl
PRG
Preliminary Remedial Goal
QAPP
Quality Assurance Project Plan
RAO
Remedial Action Objective
ROD
Record of Decision
RfD
Reference Dose
RGO
Remedial Goal Option
RI/FS
Remedial Investigation/Feasibility Study
ROD
Record of Decision
RPM
Remedial Project Manager
SAP
Sampling and Analysis Plan
SC DHEC
South Carolina Department of Health and Environmental Control
TCLP
Toxicity Characteristic Leaching Procedure
UU/UE
Unlimited Use/Unlimited Exposure
voc
Volatile Organic Compound
iv
-------
I. INTRODUCTION
The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy
to determine if the remedy is and will continue to be protective of human health and the environment.
The methods, findings, and conclusions of reviews are documented in FYR reports such as this one. In
addition, FYR reports identify issues found during the review, if any, and document recommendations to
address them.
The U.S. Environmental Protection Agency is preparing this FYR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the
National Contingency Plan (NCP) (40) Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)),
and considering EPA policy.
This is the Fourth FYR for the Beaunit Company Superfund Site. The triggering action for this statutory
review is the signature date of the previous FYR. The FYR has been prepared because hazardous
substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use and
unrestricted exposure (UU/UE).
The Site consists of one operable unit (OU), which is addressed in this FYR. OU1 addresses
contaminated soil, sediment, surface water, and groundwater.
The South Carolina Department of Health and Environmental Control (SCDHEC) conducted the FYR
and prepared this report regarding the remedy implemented at the Beaunit Company Superfund site in
Fountain Inn, Laurens County, South Carolina. The SCDHEC personnel conducted this review from
January 2018 to June 2018. The EPA is the lead agency for developing and implementing the remedy
for the cleanup at the Site. The relevant entities, including the Beaunit Lagoon Site Group (Group), were
notified of the initiation of the five-year review. The review began on 1/08/2018.
Site Background
The 1.3-acre Beaunit Corp. (Circular Knit and Dyeing Plant) Superfund site (the Site) is located on the
northwest side of Fountain Inn, South Carolina, about 15 miles southeast of the city of Greenville.
Between 1951 and 1977, the site owner operated a wastewater treatment plant on the property. Site
operations included the treatment of industrial wastewater from the knitting, dyeing and finishing plant
located about 400 yards to the east. Wastewater passed through an oil separator, into a lagoon and then
discharged into an unnamed creek located near the west end of the Site. SCDHEC conducted a site
investigation on June 13,1985 which discovered a variety of contaminants in the stagnant lagoon water,
sediments, an area creek and in fill material around the lagoon. Contaminants included benzene,
beryllium, hexavalent chromium, manganese, 2-methylnaphthalene, and naphthalene in groundwater
and arsenic and nickel in soil. The United States Environmental Protection Agency placed the Site on
the National Priorities List (NPL) on February 21,1990.
The EPA selected a remedy to address the Site's contamination in the Site's September 1995 Record of
Decision (ROD). The selected remedy, as stated in the ROD, consisted of drainage control; placement of
a soil and clay cap over the Site; grading of the Site; implementation of groundwater use restrictions
through institutional controls; and groundwater, surface water, and sediment monitoring. The Site's
potentially responsible party, the Group, conducted the remedial action from May to August 1998.
1
-------
FIVE-YEAR REVIEW SUMMARY FORM
SI I I. 11)1.\ I II l(\\TI<)\
Site Name: Beaunit Corporation Circular Knit and Dyeing Plant
EPA ID: SCD000447268
Region: 4 State: SC City/County: Fountain Inn/Greenville County
2
-------
Legend
Beaunit Corporation
Superfund Site
Scale 1:24.00
A
W- J<*M Slam Erntrormm** PuMcbof Ag»x>
Beaunit Corporation
Superfund Site
Fountain Inn, South Carolina
SCD 000 447 268
ttU USGS Fountain Inn. SC Quadrangle
Fountain Inn
Figure 1 - General Site Location Map
3
-------
Legend
Beaunit Corporation
Superfund Site
Feet
310
SS
Meters
Scale = 1:4,800
Fo>
Beaunit Corporation
Superfund Site
Fountain Inn. South Carolina
SCO 000 447 268
2018 Or—nvilla County GI3
Figure 2 - Site Location Map
4
-------
II. RESPONSE ACTION SUMMARY
Basis for Taking Action
Engineering Science conducted RI field activities at the Site from October 19,1992, to December 10,
1992. Contractor Roy F. Weston, Inc. finalized a baseline risk assessment (BRA) for the EPA on
November 24,1993, to evaluate the potential current and future risks associated with exposure to the site
contaminants.
The Remedial Investigation/Feasibility Study (RI/FS) evaluated the following media: surface water,
sediment, groundwater, surface soil and subsurface soil. The BRA determined that soil contaminants
could leach into the shallow groundwater aquifer and concluded that groundwater was the only pathway
of concern for human receptors. The contaminants of concern (COCs) for groundwater are; benzene,
beryllium, chromium (VI), manganese, 2-methylnaphthalene and naphthalene.
The EPA determined that the risks to human health from contaminants in surface soils were within its
acceptable risk range for human health. However, the BRA determined that site surface soils presented a
risk to ecological receptors, and identified arsenic and nickel as COCs.
Table 1 summarizes the COCs identified in the Site's 1988 ROD.
Table 1: COCs by Media
coc
Media
Arsenic, Nickel
Surface soil
Benzene, Beryllium, Chromium VI, Manganese, 2-
Methylnaphthalene, Naphthalene
Groundwater
Response Actions
Regulatory involvement at the Site began in the early 1970s when citizens complained to SC DHEC
regarding discoloration of the "stream below Beaunit" (referring to the unnamed creek and Howards
Branch). SC DHEC conducted a site investigation on June 13, 1985, and discovered a variety of
contaminants in the stagnant lagoon water, sediments, area creek, and fill material around the lagoon.
Contaminants discovered included polychlorinated biphenyls (PCBs), chromium, lead, and volatile
organic compounds (VOCs).
The EPA placed the Site on the NPL in February 1990. An Administrative Order on Consent (AOC) was
signed on February 21,1992 with the PRP Group (consisting of Continental Assurance Company, El
Paso Natural Gas Company, Kayser-Roth Corporation, PepsiCo, Inc., and Wilson Sporting Goods Co.)
to address the Site. The BRA was finalized on November 24,1993. The Site's RI/FS was completed and
the Record of Decision was signed on September 29,1995.
The EPA selected the Site's remedy in the Site's September 1995 Record of Decision (ROD). The ROD
listed the following remedial action objectives (RAOs):
5
-------
-Prevent human exposure, via any exposure route [ingestion and non-ingestion (i.e., showering)] to
groundwater containing contaminants in concentrations that exceed applicable or relevant and
appropriate requirements (ARARs) and appropriate risk levels.
-Prevent exposure of terrestrial species to the contaminants of concern in surface soils above appropriate
risk levels.
The selected remedy, as stated in the ROD, consisted of:
• Grading of the Site and surface water drainage control.
• Placement of a soil and clay cap over the Site.
• Groundwater use restrictions through institutional controls.
• Land use restrictions for the clay cap through institutional controls.
• A groundwater, surface water, and sediment monitoring program.
Remedial goal options (RGOs) are the Site's final cleanup goals. The initial RGO for arsenic in surface
soil was 0.1 milligrams per kilogram (mg/kg), calculated based on a hazard index of lhe background
concentration for arsenic was 3.2 mg/kg. Therefore, the ROD determined that the RGO for arsenic
should be based on background concentrations and not on the concentration calculated based on a
hazard index of 1. Table 2 presents cleanup goals for surface soil COCs.
Table 2: Surface Soil Cleanup Goals
coc
Type of Risk (Terrestrial Wildlife)
Risk-Based RGO
(me/kg)
ARAR-Based RGO (mg/kg)
Arsenic
noncarcinogenic
3.2 mg/kg"
NA
Nickel
noncarcinogenic
4.4 mg/kg
NA
Notes:
mg/kg = milligrams per kilogram
a - As stated in the ROD, the RGO for arsenic in surface soil is not risk-based, but based on the background soil
concentration of 3.2 mg/kg.
NA - Not applicable
The RGOs for groundwater COCs at the Site were developed based on an exposure scenario for a
potential future resident living on site. Table 3 presents the cleanup goals for site COCs in groundwater.
6
-------
Table 3: Groundwater Cleanup Goals
coc
Type of Risk
(Human Health)
Risk-Based* RGO
(ne/L)•
ARAR-Based RGO (fig/L)
Benzene
carcinogenic
2 to 200
5b
2-Methylnaphthalene
noncarcinogenic
3
NA
Naphthalene
noncarcinogenic
3
NA
Beryllium
carcinogenic
0.01 to 1
4b
Chromium (VI)
noncarcinogenic
40
©
o
Manganese
noncarcinogenic
40
200d
Notes:
a - Carcinogenic risk-based remediation goals are based on the risk range 1E-6 to 1E-4.
Noncarcinogenic risk-based remediation goals are based on a hazard index of 1.0.
b - ARAR-based goal is based on the maximum contaminant level (MCL).
c - ARAR-based goal is for total chromium.
d - ARAR-based goal is based on MCL goal.
e - ug/L = Micrograms per liter.
Status of Implementation
The Group took responsibility for the Site's remediation under the April 1996 Consent Decree. The
Site's completed remedial design was approved by EPA on March 6,1998. Mobilization to construct
the remedial action began on May 11,1998. Implementation of the remedial action is discussed below.
Drainage Control
During the remedial action, the Group graded the Site and constructed an earthen berm and ditch to
divert surface water from the Site. These drainage control methods prevented excessive soil erosion and
contaminant transport due to surface water runoff from the Site.
Excavation. Site Grading and Installation of a Soil and Clav Cap
Remedial actions included the excavation of a contaminated area located along the former treatment
plant influent pipeline. The initial excavation consisted of a 20 by 20 feet area by 2 feet in depth.
Confirmation soil samples taken from the excavation floor exceeded the RGOs for arsenic and nickel
(3.2 mg/kg and 4.4 mg/kg, respectively). Following additional soil excavation, a second round of
confirmatory sampling was completed. One sample from the northern sidewall was below the RGOs for
arsenic and nickel. All other confirmation samples slightly exceeded the Site's RGOs but were
sufficiently close that EPA and SCDHEC approved backfilling the excavation. The lagoon was
backfilled with a coarse aggregate gravel up to the original water level and then topped with 14,790 tons
of imported clean fill. These remedial activities were completed on June 3, 1998. The excavated soils
were determined to be nonhazardous using the toxicity characterization leaching procedure (TCLP),
then used to grade the area surrounding the lagoon.
Remedial activities also included the excavation of a visible solid waste along the eastern edge of the
lagoon consisting of approximately 410 tons of rubbery waste used in the the manufacture of tennis
balls. The solid waste was transported to an approved Subtitle D landfill for proper disposal.
As required by the ROD, the Site was graded and of a low permeability geosynthetic clay liner was
installed over the lagoon and adjacent area for a total of 61,000 square feet. An additional 940 square
feet of the clay liner was installed over the P5 excavation along the route of the former influent pipeline.
7
-------
Additional remedial actions included the placement of 12 inches of fill soil, 6 inches of topsoil, and a
vegetative layer over the liner. The cap was completed on June 24,1998. The vegetative cover is in
place and continues to provide erosion control for the capped area.
Groundwater Monitoring Program
The selected remedy in the ROD required groundwater monitoring. Eight quarterly sampling events
were conducted between July 1998 and July 2000. Annual sampling was conducted from 2001 to 2003.
The first FYR, conducted in September 2003, recommended continued annual groundwater monitoring.
Annual sampling was conducted between 2005-2006. Full scan analysis, including the COCs, was
performed for the samples collected through 2005. Based on the contaminant trends, the analyte list was
reduced in 2006 to include benzene, manganese, thallium, naphthalene, and 1,2-dichloropropane.
Annual sampling and reporting continued until 2007. The second FYR in September 2008
recommended continued groundwater monitoring on an 18-month schedule. The USEPA, SCDHEC,
and the Group agreed to reduce the analyte list to only benzene and to reduce the number of monitoring
well sampling locations to those identified in Table 4. The third FYR in September 2013 recommended
maintaining the groundwater monitoring program, updating the analytical method for benzene, and
updating the Sampling and Analysis Plan (SAP) and Quality Assurance Project Plan (QAPP) to evaluate
residual benzene concentrations in groundwater downgradient of the protective cap. The SAP/QAPP
was approved by the USEPA on September 15, 2014. In the First Quarter of 2015, a quarterly sampling
program of three monitoring wells (MW4S, TW8 and TW11) was initiated for one year to determine if
there are seasonal fluctuations in benzene concentrations and evaluate whether monitored natural
attenuation (MNA) or controlled oxygen release was a viable groundwater remedial alternative for the
residual benzene. The most recent sampling of all monitoring wells was conducted in September 2017.
8
-------
Table 4: Summary of Groundwater Monitoring Wells
(. roundwatcr Monitoring Wells at Beau nil l.a^oon Site
Groundwater Zone | Monitoring Well
Permanent Monitoring Wells
Shallow
MW-4S
MW-5S
MW-6S
Deep
MW-5D
Temporary Monitoring Wells
Shallow
TW-8
TW-9
TW-11
Surface Water Monitoring
The ROD required the monitoring and sampling of surface water and sediments at 3 locations in the
adjacent unnamed tributary of Howard Branch. Samples from these locations were collected and
analyzed semiannually for the first 2 years and annually for the following 3 years. In 2007, the EPA,
SCDHEC, and the Group agreed that it was no longer necessary to sample surface water or sediment.
Institutional Controls
The Group implemented restrictive covenants for both the capped former lagoon area and two small
parcels of land directly downgradient of the Site. These restrictions prohibit the drilling of groundwater
wells, restrict future development, and prohibit activities that would affect the integrity or effectiveness
of the cap.
9
-------
IC Summary Table
Table 5: Summary of Planned and/or Implemented Institutional Controls
Media,
Engineered
Controls and
Areas that Do Not
Support UU/UE
Based on Current
Conditions
ICs
Needed
ICs Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC Objective
Title of IC
Instrument
Implemented and
Date (or Planned)
Groundwater
Yes
Yes
0338000100700
Restrict installation of
groundwater wells.
8/31 /1998 Restrictive
Covenant
Groundwater
Yes
Yes
0338000100400*
0338000100100*
Restrict installation of
groundwater wells and
prevent any use of
groundwater without prior
written approval from the
EPA.
6/14/2010 Restrictive
Covenant
Capped Soil
Yes
No
0338000100700
Restrict activities that
would disturb the integrity
or effectiveness the cap.
8/31 /1998 Restrictive
Covenant
Soil
Yes
No
0338000100400*
0338000100100*
Restrict land use and
prohibit mining, extraction
of coal, oil, gas or any other
minerals or nonminerals on
the property.
6/14/2010 Restrictive
Covenant
~The restrictive covenant pertains to a small section of the entire parcel.
The IC documents are included in Appendix H.
10
-------
[Burgerj
ling Center
'Apartments,
XX3380Q0j1 (XfiOO]
[033WQ020I160(
[Qmonca 002001
Legend
hi:
DM
¦
i/ii/iwe
**tml
Of Country 0 m dipiniHi UC
Feet
0 310 620
1 1 1 1 1
O 95 190
Meters
Beaunit Corporation
IC Base Map
Fountain Inn. South Carolina
SCD 000 447 268
T#dhec
¦wm WiHH W> f ¦limn "W
2018 Greenville County GIS Imagery
Figure 3 - Institutional Controls Base Map
11
-------
III. PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness determinations and statements from the last five-year review as
well as the recommendations from the last five-year review and the current status of those
recommendations.
Table 6: Protectiveness Determinations/Statements from 2013 FYR
ou#
Protectiveness
Determination
Protectiveness Statement
OU1
Short-term Protective
The selected remedy currently protects human health and the environment
because exposure pathways that could result in unacceptable risks have
been addressed. The cap over the Site prevents the exposure of terrestrial
species to COCs in surface soils above appropriate risk levels and helps
prevent contaminant leaching into the shallow groundwater below.
Currently, there are no complete direct contact human exposure pathways
for groundwater at the Site. Water is available to residents and industries
through public water systems and there are no groundwater supply wells on
the site property. Institutional controls, in the form of restrictive covenants,
prevent direct human exposure to groundwater by prohibiting the drilling
of groundwater wells and restrict land uses on the cap parcel and the two
small sections of land immediately downgradient of the cap. However, in
order for the remedy to be protective in the long-term, laboratory testing
methods used to analyze benzene concentrations must be evaluated and
appropriate actions must be taken to ensure that method limits of
quantitation (LOQ) are below the benzene MCL of 5 |ig/L
Table 1: Status of Recommendations from 2013 FYR
OU#
Issue
Recommendations
Current
Status
Current
Implementation
Status Description
Completion
Date (if
applicable)
OUl
The MCL of 5 ng/L for
benzene dictates that the
testing method used to
analyze groundwater samples
should have a LOQ below 5
Hg/L. One of the testing
methods currently used has a
LOQ of 10 ug/L.
Evaluate laboratory testing
methods used to analyze
benzene concentrations and
take appropriate actions to
ensure that method LOQs
are below the benzene MCL
of 5 ng/L.
Completed
SW-846 Method 8260B
was used to analyze
groundwater samples
for benzene providing
for a reporting limit of
1.0 fig/L.
12/9/2014
TV. FIVE-YEAR REVIEW PROCESS
Community Notification. Involvement & Site Interviews
A public notice was made available by a newspaper posting in the Wednesday, April 11,2018 edition of
The Tribune Times, stating that there was a five-year review and inviting the public to submit any
comments to the USEPA. The results of the review and the report will be made available at the Site
12
-------
information repository located at the Greenville County Library at 400 North Main Street, Fountain Inn,
South Carolina 29644.
The FYR process included interviews with regulatory agencies involved in Site activities or aware of the
Site. The purpose was to document the perceived status of the Site and any perceived problems or
successes with the phases of the remedy implemented to date. All the interviews were conducted in
person, via telephone, or completed by email after the Site inspection. The interviews are summarized
below. Appendix D provides the complete interviews.
Randolph Bryant is the EPA Region 4 Remedial Project Manager (RPM) for the Site. His overall
impression of the Site is positive. The remedy has been well monitored and maintained. Sara
MacDonald works in the Bureau of Land and Waste Management Federal Remediation Program at
SCDHEC. Ms. MacDonald feels the remedy is working towards reaching remedial goals.
Data Review
Based on a recommendation from the second FYR, groundwater monitoring changed to an 18-month
schedule. The USEPA, SCDHEC, and the Group agreed to reduce the analyte list to a single COC,
benzene. The third FYR recommended an update to the analytical method for benzene with an updated
SAP/QAPP. The SAP/QAPP called for quarterly sampling of three wells for one year to determine if
there are seasonal fluctuations in benzene concentrations and evaluate whether monitored natural
attenuation (MNA) is a viable groundwater remedial alternative for the residual benzene in groundwater.
The quarterly sampling began in the First Quarter of 2015.
In 2007, the EPA, SCDHEC, and the Group agreed to reduce the analyte list to benzene only and reduce
the required sampling locations. Based on those decisions, the current groundwater monitoring system
includes four permanent monitoring wells and three temporary monitoring wells. The four permanent
wells include three shallow wells, MW-4S, MW-5S and MW-6S, and one deep well, MW-5D. The
Group installed the three temporary wells, TW-8, TW-9 and TW-11 in 2007. Table 9 shows benzene
concentrations in groundwater monitoring wells since 2006. Figures 2 and 3 show the active monitoring
well locations.
Analytical results for the September 2014 sampling event detected benzene slightly above the Site
remediation goal of 5 micrograms per Liter (ng/L) in two wells, MW-4S (5.2 fig/L) and TW-11 (6.2
jxg/L). These wells are located immediately downgradient of the cap. Benzene was detected below the
Site remediation goal in all wells during the 2015 quarterly sampling events, the March 2016 18-month
and the September 2017 18-month sampling events except for off-site downgradient well MW-5S. The
March 2016 analytical results indicated the presence of benzene at 7.3 ng/L. The September 2017
analytical results showed benzene had decreased in MW-5S to below the laboratory reporting limit (<1.0
|iL). Overall, the benzene plume appears to be shrinking with concentrations showing an overall
decreasing trend from their historic highs over the past years (Figure 4). The off-Site downgradient deep
well (MW-5D) shows and has always shown benzene concentrations below the laboratory detection
limit. It is unknown if the reported concentration from the March 2016 sampling event in MW-5S is due
to benzene plume migration or is an anomalous result. In summary, twenty-six groundwater samples
have been collected from seven monitoring wells since March 2015. Benzene was below the cleanup
goal or not detected in twenty-five of the twenty-six groundwater samples.
Select groundwater samples (MW-4S, MW-5S, MW-6S, TW-8 and TW-11) were analyzed for MNA
13
-------
parameters to evaluate the potential for benzene degradation in groundwater. A summary of
groundwater field parameters measured during sampling and MNA data is provided in Table 4. A
review of the field parameters shows that dissolved oxygen (DO) concentrations ranged between ~0 and
~10 milligrams per liter (mg/L), with slightly less than neutral pH conditions within the plume (pH
range from ~ 4 to 6). Benzene degradation continues to occur but at a relatively modest rate due to low
DO and the acidity of the groundwater.
14
-------
2007
2008
2010
2011
2013
2014
March 2015
June 2015
Sepi 2015
Dec 2015
Mar 2016
Sep 2017
2006
2007
2008
2010
2011
2013
2014
Mai 2018
Sep 2017
EXPLANATION
PERMANENT MONITORING WELL
TEMPORARY WELL
ABANDONED WELL
POTENTIOMETRIC SURFACE CONTOUR.
Ft. MSL (Dashed Where Inferred)
TOPOGRAPHIC CONTOUR
2007
2008
2010
2011
2013
2014
Marcn 2015
June 2015
Sept 2015
Dec 2015
Mar 2016
Sep 201/
BELOW METHOO DETECTION LEVEL
ESTIMATED LEVEL
MICROGRAMS PER LITER
2007 6.0
2008 52
2010 0.3 J
2011 3.9
2013 0.61 J
2014 111
Mar 2016 « 1.0
Sep 2017 0.37 J
MW-4S
2006
2007
2008
2010
2011
2013
2014
March 2015
June 2015
Sept 2015
Dec 2015
Mar 2016
Mar 2016 (Dup)
Sep 2017
UNPAVED ROAD
MW-6S
GROUNDWATER
POTENTIOMETRIC SURFACE MAP
AND BENZENE CONCENTRATIONS
Beaunit Corporation
Superfund Site
Fountain Inn, SC
Former Wastewater Lagoon
Figure 4 - Groundwater Monitoring Results
15
-------
Table 4 - Summary of Analytical Results and Field Measurement - September 2014
Monitoring
Well
Total
Iron
(Mg/L)
Total
Manganese
(Mg/L)
Sulfate
(mg/L)
Nitrate
(mg/L)
Chloride
(mg/L)
TOC
(mg/L)
Total
Alkalinity
(mg/L)
PH
Conductivity
(mS/cm)
Turbidity
(NTU)
DO
(mg/L)
0RP
(mV)
Temperature
(°C)
Benzene
Concentration
(MR/L)
MW-4S
79.2
112
35.5
ND
16.1
49.6
23.2
5.02
179
2.39
0.91
233
16.67
5.2
MW-5D
NA
NA
NA
NA
NA
NA
NA
5.90
64
0.0
8.17
218
17.87
ND<1.0
MW-5S
23.400
1.290
ND
ND
8.5
23.9
60.5
5.57
158
7.9
0.0
24
17.76
2.6
MW-5S
(Duplicate)
24,600
1.220
ND
0.027
8.5
34.6
59.8
NA
NA
NA
NA
NA
NA
2.4
MW-6S
434
52.1
u
0.24
1.8
16.7
5.0
4.99
40
9.2
0.00
201
17.46
ND<1.0
TW-8
NA
NA
NA
NA
NA
NA
NA
5.01
103
28.5
0.00
181
18.11
4.0
TW-9
NA
NA
NA
NA
NA
NA
NA
5.93
42 t 74.5
10.52
109
18.59
ND<1.0
TW-11
ND
291
ND
ND
19.1
43.8
20.5
4.50
108
23.8
2.51
220
18.28
6.2
°C ~ Celsius
mS/cm ¦ miliisiemens per centimeter
mV = millivolt
ND - Not detected
NA
= Not Analyzed
Table 4 Continued - Summary of Analytical Results and Field Measurements - March 2016
Monitoring
Well
Total
Iron
(Mg/U
Total
Manganese
(Mg/L)
Sulfate
(mg/L)
Nitrate
(mg/L)
Chloride
(mg/L)
TOC
(mg/L)
Total
Alkalinity
(mg/L)
PH
Conductivity
(mS/cm)
Turbidity
(NTU)
DO
(mg/L)
ORP
(mV)
Temperature
(°C)
Benzene
(Mg/L)
MW-4S
51.2
123
39.6
<0,02
14.8
3.9
22.2
5.13
184
1.21
0.20
194.9
20.02
1.9
MW-4S
(Duplicate)
48.1J
127
39.8
<0.02
14.6
3.6
22.3
NA
NA
NA
NA
NA
NA
17.53
2.0
<1.0
MW-5D
NA
NA
NA
NA
NA
NA
NA
6.62
53
1.61
9.03
54.2
MW-5S
48.100
1,740
1.11
<0.02
15.6
6.8
56.6
5.86
277
8.09
0.64
7.7
15.85
7.3
, .
MW-6S
2,920
176
6.3
<0.02
1.1
2.7
2.7J
5.03
34
8.9
0.30
159.7
15.89
<1.0
TW-8
<50
29.8
4.9
<0.02
~i
12.0
0.64J
5.4
4.88
66
1.22
3.28
249
16.65
<1.0
TW-9
NA
NA
NA
NA
NA
NA
NA
5.40
29
96,7
9.6
153.5
17.35
<1.0
TW-11
1.090
220
<2.0
<0.02
20.0
15.6
2.7J
4.92
76
3.83
2.01
204.5
16.45
<1.0
*C « Celsius mS/cm = miliisiemens per centimeter mV » millivolt NA ~ Not Analyzed mg/L = milligrams per Liter
fg/L = micrograms per Liter TOC = Total Organic Carbon NTU = Nephelometric Turbidity Unit
Table 4 Continued - Summary of Analytical Results and Field Measurement
September 2017
Monitoring
Well
Total
Iron
(Mg/L)
Total
Manganese
(Mg/L)
Sulfate
(mg/L)
Nitrate
(mg/L)
Chloride
(mg/L)
Total
TOC ... .. .
Alkalinity
"s'u w"
Conductivity
P (MS/cm)
Turbidity
(NTU)
DO
(mg/L)
ORP
(mV)
Temperature
(°C)
Benzene
(Mg/L)
MW-4S
<50.0
99.1
34.2
<0.10
11.0
2.7
16.1
3.22
0.161
0.98
0.81
122.4
17.82
18.17
1.0
<1.0
MW-5D
NA
NA
NA
NA
NA
NA
NA
5.96
0.069
0.15
10.33
110.1
MW-5S
2,850
587
<1.0
0.13
7.1
0.90 J
23.4
3.19
0.061
0.41
0.59
178.0
18.51
<1.0
MW-5S
(Duplicate)
NA
NA
NA
NA
NA
NA
NA
3.19
0.061
0.41
0.59
178.0
18.51
<1.0
MW-6S
213
68.5
6.0
0.12
1.1
1.9
3.1 J
2.26
0.037
8.72
3.67
181.1
20.49
<1.0
TW-8
NA
NA
NA
NA
NA
NA
NA
4.29
0.112
0.00
0.93
-23.9
16.58
4.1
TW-9
NA
NA
NA
NA
NA
NA
NA
4.47
0.074
95.7
9.21
135.1
19.43
0.37 J
TW-11
35.6 J
342
2.9
<0.10
22.1
4.7
21.1
4.79
0.133
2.97
2.91
49.8
17.14
3.0
*C = Celsius uS/cm « mlcrosiemens per centimeter mV = millivolt NA - Not Analyzed
/tg/L - micrograms per Liter TOC - Total Organic Carbon NTU = Nephelometric mg/L ¦ milligrams per Liter
J = Estimated value Turbidity Unit
16
-------
Site Inspection
The site inspection took place on June 26, 2018. In attendance were the EPA RPM Randolph Bryant, the
PRP's contractor, Reinhard Ruhmke, and Sara MacDonald, Joel Padgett, and Timothy Kadar from
SCDHEC. The purpose was to assess the protectiveness of the remedy. For a full list of site inspection
activities, see the Site Inspection Checklist in Appendix D.
Participants accessed the Site via Valley View Road. The Contractor provided a brief history of the Site
and a Health and Safety briefing. The cap covers the entire Site. The Site is enclosed within a chain link
fence with a locked gate. The chain link fence and gate were found to be in good condition. The wells,
both on and off the Site, were properly secured and in good condition. Participants performed a walk-
through survey of the Site stopping at multiple locations to inspect wells, site conditions, etc. Conditions
remain similar to those that existed five years ago.
SCDHEC staff visited the designated Site repository, the Greenville County Public Library, located at
400 North Main Street, Fountain Inn, South Carolina. No Site related documents were on file at the
repository. The Library requests that documentation be made available in a secure electronic format,
preferably a website containing all relevant information. The Library can then provide access via the
publicly available computers onsite and the appropriate website link.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary:
The review of documents, ARARs, risk assumptions, and the site inspection indicate that the remedy is
functioning as intended by the Site's decision document. During implementation of the remedy selected
in the 1995 ROD, the former lagoon area was capped with a low-permeability geosynthetic clay liner, 18
inches of clay, 12 inches of native topsoil, and a vegetative cover. The cap prevents the exposure of
terrestrial species to COCs in surface soils at concentrations above appropriate risk levels and helps
prevent contaminants from leaching into the shallow groundwater below.
The consent decree required the Group to perform all required O&M activities including the periodic
inspection and maintenance of the cap, vegetative cover, fence, gate, monitoring wells, and warning
signs. The Site is in good condition, with no maintenance issues observed during the FYR site
inspection.
The ROD required institutional controls to maintain the integrity of the cap and prevent the use of
groundwater on the Site. A restrictive covenant, dated August 31,1998, prohibits activities that would
affect the integrity or effectiveness of the cap, and prohibits the drilling of groundwater supply wells on
the Site. There are no groundwater supply wells on the site property, therefore there are no completed
direct contact human exposure pathways for groundwater at the Site. Water is available to nearby
residents and industries through public water supply systems that provide drinking water from a non-
local surface water source.
17
-------
A second restrictive covenant, dated June 14,2010, is in effect for two small sections of land
immediately downgradient of the Site. The covenant prohibits the drilling of groundwater wells on the
properties without prior written approval from the EPA. Although not required by the ROD, the
restrictive covenant also prohibits residential and agricultural land uses, child day care facilities, schools
and elderly care facilities on the properties. It also prohibits use of the properties for mining or
extraction of coal, oil, gas, or any other minerals or non-mineral substances.
The ROD required the implementation of a groundwater, surface water, and sediment monitoring
program. Eight post-RA sampling events were conducted between July 1998 and July 2000. Annual
sampling was conducted between 2001-2003 and 2005-2006. Full scan analysis, including the COCs,
was performed for the samples collected through 2005. Based on the contaminant trends, the analyte list
was reduced in 2006 to. include only benzene, manganese, thallium, naphthalene, and 1,2-
dichloropropane. Based on the surface water and sediment monitoring results through 2006, the EPA
approved the removal of those media from the required monitoring schedule. The Group performs
required groundwater monitoring every 18 months to ensure that the remedy is functioning properly.
Groundwater monitoring data over the previous five years indicates that benzene degradation continues
to occur at a relatively modest rate. The latest analytical results from September 2017 did not detect
benzene above the MCL of 5 (ig/L in any monitoring well.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time
of the remedy selection still valid?
Question B Summary:
ARARs used at the time of the remedy selection are still valid. The groundwater ARARs have not
changed for any of the COCs since the 1995 ROD.
The 1993 BRA determined that the risks to human health from contaminants in surface soils were within
the EPA's acceptable risk range and that remediation of surface soils would not be required for the
protection of human health. However, the BRA also determined that site surface soils did present a risk
to ecological receptors. Arsenic and nickel were identified as the chemicals of concern. It was also
possible that soil contaminants could leach into the shallow groundwater aquifer. The cap over the
former lagoon area prevents the exposure of terrestrial species to COCs in surface soils above
appropriate risk levels and helps prevent contaminant leaching into the shallow groundwater below.
The soil cleanup level identified in the ROD for nickel (4.4 mg/kg) is below the current soil screening
levels for industrial land use (22,000 mg/kg) and residential land use (1,500 mg/kg). The EPA set the
soil cleanup goal for arsenic (3.2 mg/kg) based on background soil arsenic concentrations. Even though
the soil cleanup goal for arsenic is not below the current soil screening levels for industrial land use (1.6
mg/kg) or residential land use (0.39 mg/kg), the cap over the Site prevents any human or ecological
exposure to soils that may exceed the current screening levels. Additionally, land use restrictions for the
cap ensure cap integrity and further prevent possible exposure to soil that may exceed current screening
levels.
The 1993 BRA determined that potential future residential groundwater exposures to benzene,
beryllium, chromium, manganese, 2-methylnaphthalene and naphthalene were of concern. Both the
1998 and 2010 restrictive covenants prohibit the drilling of groundwater wells on the cap and the land
located between the cap and Valley View Road. Additionally, the 2010 restrictive covenant prohibits
18
-------
residential land use in the areas located immediately downgradient of the cap and the 1998 restrictive
covenant prohibits any activity which would disturb the integrity and effectiveness of the cap.
Site contamination included some levels of PCB contamination in soil, sediment and fill material.
Remedial investigation records identify a maximum soil concentration of 13 ng/kg, a maximum
sediment concentration of 74 ng/kg and a maximum fill material concentration of 28 (ig/kg. PCB-related
cleanup goals were not established for on-site media. However, the concentrations detected during the
RI are below the current soil screening levels for PCBs (740 fig/kg for industrial soil and 220 ng/kg for
residential soil).
The 1995 ROD based some of the Site's cleanup goals on site-specific risk. To help determine whether
these cleanup goals are still valid, this FYR compared the toxicity values used in the 1993 RI/FS against
current toxicity values. Appendix F presents this comparison. Of the four COCs with risk-based cleanup
goals, arsenic and beryllium have toxicity values that are more stringent now (1.5E+00 mg/kg-day-1 and
2.0E-03 mg/kg-day, respectively) than at the time of the 1993 RI/FS (1.8E+00 mg/kg-day-1 and 5.0E-
03mg/kg-day, respectively). However, the construction of the cap over the contaminated surface soil
effectively eliminates any potential human or ecological exposure to soils that may contain COCs at
concentrations exceeding the current toxicity values. Despite the more stringent current values, there is
no complete exposure pathway.
The RAOs used at the time of remedy selection are still valid.
QUESTION C: Has any other information come to light that could call into question the protectiveness
of the remedy?
No other information has come to light that could call into question the protectiveness of the remedy.
19
-------
VI. ISSUES/RECOMMENDATIONS
OU(s) without Issues/Recommendations Identified in the FYR:
OU1
VII. PROTECTIVENESS STATEMENT
Operable Unit:
Protectiveness Determination:
Protective
OU1
Protectiveness Statement:
The remedy at OU1 protects human health and the environment because exposure pathways that could
result in unacceptable risks have been addressed. The cap over the Site prevents the exposure of
terrestrial species to COCs in surface soils above appropriate risk levels and helps prevent contaminant
leaching into the shallow groundwater. Currently, there are no complete direct contact human exposure
pathways for groundwater at the Site. Restrictive covenant (ICs) prohibit the drilling of groundwater
wells and restrict land uses on the cap parcel and the two small sections of land immediately
downgradient of the cap.
The next FYR for the Site is required five years from the completion date of this review.
VIII. NEXT REVIEW
20
-------
APPENDIX A - REFERENCE LIST
Remedial Investigation Report, Beaunit Corp. Circular Knit & Dyeing Plant, Fountain Inn, Greenville
County, South Carolina. Prepared for Beaunit Lagoon Site Group by Engineering-Science, Inc.
August 1993.
Record of Decision, Beaunit Circular Knit and Dyeing Superfund Site, Fountain Inn, Greenville County,
South Carolina. United States Environmental Protection Agency Region 4. September 29r 1995.
Final (100%) Remedial Design for Beaunit Corp. Circular Knit & Dyeing Plant, Fountain Inn,
Greenville County, South Carolina. Prepared for Beaunit Lagoon Site Group by Engineering-
Science, Inc. September 17, 1997.
Operation and Maintenance Plan, Beaunit Corp. Circular Knit & Dyeing Plant, Fountain Inn, Greenville
County, South Carolina. Prepared for Beaunit Lagoon Site Group by Parsons Engineering
Science, Inc. July 28, 1998.
Remedial Action Report and Construction Inspection Report for Beaunit Corp. Circular Knit & Dyeing
Plant NPL Site. Prepared for Beaunit Lagoon Site Group by Parsons Engineering Science, Inc.
September 1,1998.
Preliminary Close Out Report, Beaunit Circular Knit & Dyeing Site, Fountain Inn, Greenville County,
South Carolina. United States Environmental Protection Agency Region 4. September 25, 1998.
First Five-Year Review Report for Beaunit Corp. (Circular Knit & Dyeing Plant) Superfund Site,
Fountain Inn, Greenville County, South Carolina. Prepared for United States Environmental
Protection Agency Region 4 by U.S. Army Corps of Engineers, Savannah District. September
30, 2003.
Second Five-Year Review Report for Beaunit Corp. (Circular Knit & Dyeing Plant) Superfund Site,
Fountain Inn, Greenville County, South Carolina. United States Environmental Protection
Agency Region 4. September 30,2008.
Third Five-Year Review Report for Beaunit Corp. (Circular Knit & Dyeing Plant) Superfund Site,
Fountain Inn, Greenville County, South Carolina. United States Environmental Protection
Agency Region 4. September 25,2013.
Groundwater Sampling Report, Beaunit Corporation Circular Knit and Dyeing Plant Site, Fountain Inn,
South Carolina. Prepared for El Paso Natural Gas Company by Brown and Caldwell. December
9,2014.
Groundwater Sampling Report, Beaunit Corporation Circular Knit and Dyeing Plant Site, Fountain Inn,
South Carolina. Prepared for EI Paso Natural Gas Company by Brown and Caldwell. September
30,2016.
A-l
-------
Groundwater Sampling Report, Beaunit Corporation Circular Knit and Dyeing Plant Site, Fountain Inn,
South Carolina. Prepared for El Paso Natural Gas Company by Brown and Caldwell. December
29,2017.
A-2
-------
APPENDIX B - CURRENT SITE STATUS
Tn\ iromiu'iitnl I ndicators
Arc Necessary Insli(nI Controls in I'lacc?
All O Some Q None
Yes
Has ICI'A besiiiiiatcd the Site as Sitcw idc Ready lor Anticipated Use?
| E3 Yes ~No
Has the Site Been Put into Kcusc?
| ~ Yes Efl
No
B-l
-------
APPENDIX C - PRESS NOTICE
t£he(D(eemnUelte
WVTOF THE USA TODAY NETWQtK
Classified Ad Receipt
(For Info Only - NOT A BILL)
Customer SITE ASSESSMENT & REMEDIATION
Address: 2600 BULL ST
COLUMBIA SC 29201
USA
Run Times: 1
Run Dates: 04/11/18
Text of Ad:
2B41738 Beaunit
PUBLIC NOTICE
Five Year Review of the Beaunit Corp.
(Circular Knit and Dyeing Plant)
Greenville County, South Carolina
The U.S. Environmental Protection Agency (EPA) and the South Carolina Department
of Health and Environmental Control TDHtQ are conducting a Five-Year Review of the
former Beaunit Corp. (Circular Knit and Dyeing Plant) site located in Fountain Inn,
South Carolina. This is a federal Superfund site with ongoing monitoring activities.
The purpose of the review is to evaluate the monitoring results and site conditions
and make sure that the cleanup continues to protect human health and the environ-
ment. During the review, DHEl staff will conduct interviews with local residents offi-
cials, and others who are familiar with the site. We value input about site conditions
and want to hear any concerns of the local community. You are encouraged to partici-
pate in the review by contacting us with your comments or questions through May 7,
The Five-Year Review process is expected to be complete by September 2018, at which
time a report will be written on our findings. Any comments received about the she
will be summarized in the report The report will be available on EPA's website and at
the Greenville County Library at 400 North Main Street, Fountain inn. South Carolina.
For more information about the Beaunit Corp. (Circular Knit and Dyeing Plant) site,
please visit httpsi/Awww.epa.govftuperfund/beaunit
For comments, questions or to participate in an interview, please contact:
Technical Comments: Randy Bryant EPA Project Manager, at (404) S62-8794, or by e-
mail at Bryant.RandyOepa.gov
Community Involvement: Donna Moye, DHEC Community Liaison, at (803) 898-1382,
or by e-mail at moyeddOdhecsc.gov
Please share this with others you know who might be interested.
C-l
-------
APPENDIX D - SITE INSPECTION CHECKLIST
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST
I. SITE INFORMATION
Site Name: Beaunit Corp. (Circular Knit & Dyeing
Plant)
Date of Inspection: 6/26/2018
Location and Region: Fountain Inn, SC Region 4
EPA ID: SCD000447268
Agency, Office or Company Leading the Five-Year
Review: EPA Region 4
Weather/Temperature: 90 degrees Fahrenheit and
clear
Remedy Includes: (Check all that apply)
El Landfill cover/containment
13 Access controls
13 Institutional controls
I~1 Ground water pump and treatment
~ Surface water collection and treatment
[~~| Other:
E3 Monitored natural attenuation
~ Ground water containment
~ Vertical barrier walls
Attachments: l~~l Inspection team roster attached .
El Site map attached
II. INTERVIEWS (check all that apply)
1. O&M Site Manager Matt Aufman Brown and Cauldwell
Name Hvdroeeoloeist
Title
Interviewed 15^ at site r~| at office (~~l bv phone Phone:
Problems, suggestions ~ Report attached:
6/5/2018
Date
2. O&M Stan-
Name
Interviewed Q at site ~ at office ~ by phone :
Problems/suggestions [~1 Report attached:
Title
mm/dd/ww
Date
D-l
-------
3.
Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices). Fill in all that apply.
Aeencv SC DHEC
Contact Sara MacDonald Site Manager 6/12/2018
Name Title Date
Problems/sueeestions PI Reoort attached: See ADDendix C
Phone No.
Aeencv
Contact Name
Title
Problems/suseestions I-! Report attached:
Date
Phone No.
Aeencv
Contact
Name Title
Problems/sueeestions PI Report attached:
Date
Phone No.
Aeencv
Contact
Name Title
Problems/sueeestions IH Report attached:
Date
Phone No.
Aeencv
Contact
Name Title
Problems/suggestions |~~| Report attached:
Date
Phone No.
4. .
Other Interviews (optional) PI Report attached:
III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)
1.
O&M Documents
l~l O&M manual ^ Readily available
~ Up to date
~ n/a
l~l As-built drawings ~ Readily available
~ Up to date
^N/A
l~l Maintenance logs ^ Readily available
I~1 Up to date
~ n/a
Remarks:
2.
Site-Specific Health and Safety Plan
E3 Readily available
£3 Up to date ~ N/A
~ Contingency plan/emergency response plan
l~l Readily available
~ Up to date ^ N/A
Remarks:
3.
O&M and OSHA Training Records
Remarks:
£3 Readily available
1X1 Up to date |_| N/A
D-2
-------
4.
Permits and Service Agreements
~ Air discharge permit
~ Effluent discharge
n Waste disposal, POTW
["1 Other oermits:
Remarks:
~ Readily available
~ Readily available
~ Readily available
~ Readily available
~ Up to date
~ Up to date
|~~1 Up to date
Q Up to date
En/a
^N/A
Sn/a
§N/A
5.
Gas Generation Records
Remarks:
~ Readily available
[~| Up to date
0N/A
6.
Settlement Monument Records
Remarks:
~ Readily available
~ Up to date
^N/A
7.
Ground Water Monitoring Records
Remarks:
£3 Readily available
1^1 Up to date
~ n/a
8.
Leachate Extraction Records
Remarks:
~ Readily available
~ Up to date
E3n/a
9.
Discharge Compliance Records
~ Air ~ Readily available ~ Up to date
~ Water (effluent) ~ Readily available ~ Up to date
Remarks:
Sn/a
EIn/a
10.
Daily Access/Security Logs
Remarks:
~ Readily available
~ Up to date
Sn/a
IV. O&M COSTS
1.
O&M Organization
~ State in-house
[~~l PRP in-house
I~1 Federal facility in-house
n
~ Contractor for state
^ Contractor for PRP
[~~l Contractor for Federal facility
D-3
-------
2. O&M Cost Records
^3 Readily available ^ Up to date
l"~l Funding mechanism/agreement in place O Unavailable
Original O&M cost estimate: I~1 Breakdown attached
Total annual cost by year for review period if available
From: / / To: / / ¦ I~1 Breakdown attached
Date Date Total cost
From: / / To: / / Q Breakdown attached
Date Date Total cost
From: / / To: / / O Breakdown attached
Date Date Total cost
From: / / To: / / ~ Breakdown attached
Date Date Total cost
From: / / To: / / ~ Breakdown attached
Date Date Total cost
3. Unanticipated or Unusually High O&M Costs during Review Period
Describe costs and reasons:
V. ACCESS AND INSTITUTIONAL CONTROLS ^Applicable ~ N/A
A. Fencing
1. Fencing Damaged ~ Location shown on site map El Gates secured ~ N/A
Remarks: Perimeter fence is in good repair with locked gates and signage.
B. Other Access Restrictions
1. Signs and Other Security Measures Q Location shown on site map ~ N/A
Remarks: Contact information on signage is in process of being updated.
D-4
-------
C. Institutional Controls (ICs)
1. Implementation and Enforcement
Site conditions imply ICs not properly implemented
Site conditions imply ICs not being fully enforced
Type of monitoring (e.g., self-reporting, drive by): Self-reporting
Frequency:
Responsible party/agency: PRP
Contact Randolph Brvant EPA RPM
Name Title
Reporting is up to date
Reports are verified by the lead agency
Specific requirements in deed or decision documents have been met
Violations have been reported
Other problems or suggestions: ~ Report attached
~ Yes ^ No ~ N/A
~ Yes El No Q N/A
mm/dd/ww
Date
Phone no.
D Yes
~
No
E|n/a
~ Yes
~
No
El N/A
S Yes
~
No
~ n/a
D Yes
~
No
^ N/A
2. Adequacy
£3 ICs are adequate
~ ICs are inadequate
~ N/A
Remarks: Institutional controls in the form of restrictive covenants prevent direct human exposure to
ground water bv prohibiting the drilling of ground water wells and restrict land use for the cap parcel and
two small land areas immediately downgradient of the capJ
D.
General
1.
Vandalism/Trespassing ~ Location shown on site map
Remarks:
^ No vandalism evident
2.
Land Use Changes On Site ^ N/A
Remarks:
3.
Land Use Changes Off Site £3 N/A
Remarks:
VI. GENERAL SITE CONDITIONS
A.
Roads ^ Applicable ~ N/A
1.
Roads Damaged ~ Location shown on site map
Remarks:
El Roads adequate Q N/A
B. Other Site Conditions
Remarks:
D-5
-------
VII. LANDFILL COVERS ^Applicable
<
~
A.
Landfill Surface
1.
Settlement (low spots)
~ Location shown on site map
Settlement not evident
Arial extent:
Depth:
Remarks:
2.
Cracks
I~1 Location shown on site map
Rl Cracking not evident
Lengths:
Widths:
Depths:
Remarks:
3.
Erosion
I~1 Location shown on site map
53 Erosion not evident
Arial extent:
Depth:
Remarks:
4.
Holes
l~l Location shown on site map
^ Holes not evident
Arial extent:
Depth:
Remarks:
5.
Vegetative Cover
~ Grass
13 Cover properly established
I~1 No signs of stress
~ Trees/shrubs (indicate size and locations on a diagram)
Remarks:
6.
Alternative Cover (e.g., armored rock, concrete)
^N/A
Remarks:
7.
Bulges
l~l Location shown on site map
£3 Bulges not evident
Arial extent:
Height:
Remarks:
8.
Wet Areas/Water Damage
E3 Wet areas/water damage not evident
1 1 Wet areas
l~l Location shown on site map
Arial extent:
l~~l Ponding
~ Location shown on site map
Arial extent:
I~1 Seeps
~ Location shown on site map
Arial extent:
~ Soft subgrade
l~~l Location shown on site map
Arial extent:
Remarks:
9.
Slope Instability
r 1 Slides
~ Location shown on site map
E3 No evidence of slope instability
Arial extent:
Remarks:
D-6
-------
B.
Benches ~ Applicable ^ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in
order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
1.
Flows Bypass Bench
Remarks:
[~| Location shown on site map
I~1 N/A or okay
2.
Bench Breached
Remarks:
~ Location shown on site map
f~~l N/A or okay
3.
Bench Overtopped
Remarks:
I~1 Location shown on site map
l~"l N/A or okay
C.
Letdown Channels
I~1 Applicable ^ N/A
(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement (Low spots)
Arial extent:
Remarks:
~ Location shown on site map
~ No evidence of settlement
DeDth:
2.
Material Degradation
Material tvoe:
Remarks:
~ Location shown on site map
~ No evidence of degradation
Arial extent:
3.
Erosion
Arial extent:
Remarks:
~ Location shown on site map
~ No evidence of erosion
DeDth:
4.
Undercutting
Arial extent:
Remarks:
~ Location shown on site map
~ No evidence of undercutting
DeDth:
5.
Obstructions
Type:
~ No obstructions
~ Location shown on site map Arial extent:
Size:
Remarks:
6.
Excessive Vegetative Growth Tvpe:
~ No evidence of excessive growth
f~l Vegetation in channels does not obstruct flow
|~1 Location shown on site map Arial extent:
Remarks:
D-7
-------
D. Cover Penetrations ~ Applicable £3 N/A
1.
Gas Vents ~ Active
l~l Passive
I~1 Properly secured/locked ~ Functioning
~ Routinely sampled
I~1 Good condition
l~| Evidence of leakage at penetration
I~1 Needs maintenance
~ n/a
Remarks:
2.
Gas Monitoring Probes
I"! Properly secured/locked ~ Functioning
l~l Routinely sampled
n Good condition
I~1 Evidence of leakage at penetration
l~l Needs maintenance
~ n/a
Remarks:
3.
Monitoring Wells (within surface area of landfill)
l~"l Properly secured/locked ~ Functioning
[~l Routinely sampled
~ Good condition
n Evidence of leakage at penetration
~ Needs maintenance
~ n/a
Remarks:
4.
Extraction Wells Leachate
l~"l Properly secured/locked ~ Functioning
~ Routinely sampled
~ Good condition
f"| Evidence of leakage at penetration
~ Needs maintenance
~ n/a
Remarks:
. 5.
Settlement Monuments ~ Located
l~~l Routinely surveyed
~ n/a
Remarks:
E.
Gas Collection and Treatment ~ Applicable
13 N/A
1.
Gas Treatment Facilities
l~"l Flaring ~ Thermail destruction
~ Collection for reuse
l~1 Good condition ~ Needs maintenance
Remarks:
2.
Gas Collection Wells, Manifolds and Piping
PI Good condition ~ Needs maintenance
Remarks:
3.
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
l~~1 Good condition ~ Needs maintenance ~ N/A
Remarks:
F.
Cover Drainage Layer ~ Applicable
^ N/A
1.
Outlet Pipes Inspected ~ Functioning
~ n/a
Remarks:
2.
Outlet Rock Inspected ~ Functioning
~ n/a
Remarks:
G.
Detention/Sedimentation Ponds ~ Applicable
^n/a
D-8
-------
1.
Siltation Area extent: Depth:
~ n/a
I~1 Siltation not evident
Remarks:
2.
Erosion Area extent: Depth:
l~l Erosion not evident
Remarks:
3.
Outlet Works ~ Functioning
~ n/a
Remarks:
4.
Dam ~ Functioning
~ n/a
Remarks:
H. Retaining Walls
Q Applicable ^ N/A
1.
Deformations
I~1 Location shown on site map
f~l Deformation not evident
Horizontal displacement:
Vertical displacement:
Rotational displacement:
Remarks:
2.
Degradation
l~i Location shown on site map
f~~l Degradation not evident
Remarks:
I. Perimeter Ditches/Off-Site Discharge ~ Applicable
0N/A
1.
Siltation
[~] Location shown on site map
~ Siltation not evident
Area extent:
Deoth:
Remarks:
2.
Vegetative Growth
~ Location shown on site map
~ n/a
~ Vegetation does not impede flow
Area extent:
Type:
Remarks:
3.
Erosion
l~~l Location shown on site map
~ Erosion not evident
Area extent:
DeDth:
Remarks:
4.
Discharge Structure
l~l Functioning
~ n/a
Remarks:
D-9
-------
VIIL VERTICAL BARRIER WALLS ~ Applicable M N/A
1.
Settlement Q Location shown on site map Q Settlement not evident
Area extent: Depth:
Remarks:
2.
Performance Monitoring Tvpe of monitoring:
l~~l Performance not monitored
Freauencv: I-! Evidence of breaching
Head differential:
Remarks:
IX.
GROUND WATER/SURFACE WATER REMEDIES ^Applicable ~ N/A
A.
Ground Water Extraction Wells, Pumps and Pipelines Q Applicable ^ N/A
1.
Pumps, Wellhead Plumbing and Electrical
l~~l Good condition Q All required wells properly operating O Needs maintenance O N/A
Remarks:
2.
Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances
f~1 Good condition O Needs maintenance
Remarks:
3.
Spare Parts and Equipment
I~1 Readily available ~ Good condition ~ Requires upgrade Q Needs to be provided
Remarks:
B. Surface Water Collection Structures, Pumps and Pipelines Q Applicable ^ N/A
1.
Collection Structures, Pumps and Electrical
f~l Good condition ~ Needs maintenance
Remarks:
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances
~ Good condition ~ Needs maintenance
Remarks:
3.
Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:
D-10
-------
c.
Treatment System Q Applicable |^N/A
1.
Treatment Train (check components that apply)
l~l Metals removal ~ Oil/water separation ~ Bioremediation
l~~l Air stripping Q Carbon adsorbers
I-! Filters:
I-! Additive (e.a.. chelation aeent. flocculent):
n Others:
~ Good condition ~ Needs maintenance
~ Sampling ports properly marked and functional
l~l Sampling/maintenance log displayed and up to date
I~1 Equipment properly identified
I"! Ouantitv of eround water treated annuallv:
f~l Ouantitv of surface water treated annuallv:
Remarks:
2.
Electrical Enclosures and Panels (properly rated and functional)
~ N/A ~ Good condition ~ Needs maintenance
Remarks:
3.
Tanks, Vaults, Storage Vessels
I~1 N/A n Good condition ~ Proper secondary containment
Remarks:
~ Needs maintenance
4.
Discharge Structure and Appurtenances
~ N/A ~ Good condition ~ Needs maintenance
Remarks:
5.
Treatment Building(s)
~ N/A ~ Good condition (esp. roof and doorways)
~ Chemicals and equipment properly stored
Remarks:
~ Needs repair
6.
Monitoring Wells (pump and treatment remedy)
I~1 Properly secured/locked O Functioning Q Routinely sampled
~ Good condition
I~1 All required wells located O Needs maintenance
Remarks:
~ n/a
D. Monitoring Data
D-ll
-------
1. Monitoring Data
^ Is routinely submitted on time
M Is of acceptable quality
2. Monitoring Data Suggests:
El Ground water plume is effectively contained
i
£3 Contaminant concentrations are declining
E. Monitored Natural Attenuation
1. Monitoring Wells (natural attenuation remedy)
0 Properly secured/locked El Functioning ^ Routinely sampled El Good condition
El All required wells located ~ Needs maintenance Q N/A
Remarks:
X. OTHER REMEDIES
If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
XI. OVERALL OBSERVATIONS
A. Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).
The site remedy consists of a clav cap over the Site and institutional controls and monitoring to ensure'
groundwater plume is not migrating and is adequately contained. The cap over the Site prevents the
exposure of terrestrial species to COCs in surface soils above appropriate risk levels and helps prevent
contaminant leaching into the shallow groundwater below. Currently, there are no complete direct contact
human exposure pathways for groundwater at the Site. Water is available to residents and industries
through public water systems and there are no groundwater supply wells on the site property. Institutional
controls, in the form of restrictive covenants, prevent direct human exposure to ground water bv
prohibiting the drilling of groundwater wells and restrict land use for the cap parcel and two small sections
of land immediately down gradient of the cap. Based on a review of groundwater monitoring data from the!
previous five years, it appears that the plume is stable and contained within the institutional control
boundaries and that overall, benzene concentrations have decreased to below the MCL of 5 ue/L.
B. Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
The Site appears to be in good condition and well maintained]
C. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised
in the future.
Ngne
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
None
Site Inspection Participants:
Randolph Bryant, EPA RPM
Joel Padgett, SCDHEC PM
Sara MacDonald, SCDHEC
Timothy Kadar, SCDHEC
D-12
-------
Entry gate at the Site facing WSW, capped lagoon behind fence. June 26, 2018.
D-13
-------
Perimeter fence around capped lagoon, facing WNW. June 26, 2018.
D-14
-------
APPENDIX E - INTERVIEW FORMS
Interview Form for Five-Year Review
Site Name:
Interviewer's Name:
Interviewee's Name:
Beaunit Corporation
Timothy Radar
Sara Mac Dona Id
Project Manager
Affiliation: SCDIiEC
Affiliation: SCDIIKC. Federal Remediation
Contact Information: SCDHI.C
2600 Bull Street
Columbia, SC 2920!
tnacdottsiiflidhec.se.gov
Type of Interview: llmail
Date: May 30,2018
1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?
The overall impression of the site is positive. The fence around the capped area is overgrown with vegetation, but
keeps out trespassers that may damage the cap. There is coneem about reuse activities because soil from a hot spot
removal action was used to grade the outside of I he capped area,
2. What is your assessment of the current performance of the remedy in place at the Site?
The cap and the drainage features surrounding the cap work to mitigate the groundwater contamination. The past
sampling event showed that the remaining constituent, benzene, is below remedial goals in all wells. If the cap and
drainage features remain intact, the remedy in place appears to work for long-term protection of the environment
and human health.
3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial activities
from residents in the past five years?
Gail Jeter from Cardno (803-210-6080) called to talk about what is classified as the superfund property. The Mayor
of fountain Inn calls the Superfund site an -eyesore" and wants to develop it. Ms. Jeter wanted to know die status
of the site, what properties have iCs on them, and what investigation work was done. There is also a question
regarding if and when the ICs on surrounding properties will be removed once there is no longer groundwater
contamination migrating onto the properties.
4. Has your office conducted any site-related activities or communications in the past five years? If so, please
describe the purpose and results of these activities.
A site visit was made after Hurricane Irma to check the integrity of the cap and drainage features. Reviews of the
sampling reports have been completed and any comments forwarded to EPA and Brown and Caldwell.
-1
-------
5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy?
I am not aware of any changes to state laws that might affect the protectiveness of the Site's remedy,
6. Are you comfortable with the status of the institutional controls at the Site? If not, what are the associated
outstanding issues?
Institutional controls appear to be adequate for the site.
7. Are you aware of any changes in projected land use(s) at the Site?
Gail Jeter from Cardno called to find information about investigations done on properties surrounding the Site. The
City of Fountain Inn is interested in development of the land surrounding the Site and is preparing to do Phase 1
investigations.
8. Do you have any comments, suggestions or recommendations regarding the management or operation of the
Site's remedy?
The only concern at the moment is the hot spot removal action that was completed. The contaminated soil was
removed, but then was used to grade an area outside of the cap. The site may be used as a mixed residential area,
therefore, a file review and, if necessary, confirmation sampling of this exposed soil should be completed before
delisting to ensure safety for future residents.
-------
Interview Form for Five-Year Review
Site Name;
Interviewer's Name:
Interviewee's Name:
Beaunir Corporation Super fund Site
Timothy Kadar
Randolph Bryant
Remedial Project Manager
Affiliation: SCD1IFC
Affiliation: f PA. SRS1 B
Contact Information: US EPA Region 4
61 Forsyth Street
Atlanta, GA 30303
Bryant. It8ndv-fttepa.gov
Type of Interview: Email
Date: May 30,2018
1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)? The
cleanup was completed in 1998. Periodic maintenance and monitoring is ongoing and has been conducted appropriately. 1 am
not aware of any planned reuse activities. Any future reuse would have to be protective of the installed cap.
2. What is your assessment of the current performance of the remedy in place at the Site? The remedy is performing as intended
and is protective of human health and the environment.
3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial activities from residents
in the past five years? No.
4. Has your office conducted any site-related activities or communications in the past five years? If so, please describe the
purpose and results of these activities. EPA's activities during this period have been related to reviews of the annual
groundwater monitoring reports. EPA also visited the Site in September 2017 and confirmed the lack of storm damage from
Hurricane/Tropical Storm lrma.
5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy? No.
6. Are you comfortable with the status of the institutional controls at the Site? If not, what are the associated outstanding issues?
Yes. The institutional controls have been in place since 1998 and 2010, respectively, for parcels associated with the Site.
?. Are you aware of any changes in projected land use(s) at the Site? No.
8. Do you have any comments, suggestions or recommendations regarding the management or operation of the Site's remedy?
Groundwater quality has been improving since completion of the soil remedy. Benzene, the remaining contaminant of concern
in groundwater, has been below the cleanup goal in all but one monitoring well since 2015. Furthermore, benzene in
groundwater was below the cleanup goal in all monitoring wells during the most recent sampling which occurred in 2017,
-3
-------
APPENDIX F - DETAILED ARARs REVIEW
Appendix E includes a review of relevant, site-related documents including the RODs, AROD, ESDs,
remedial action reports and recent monitoring data.
CERCLA Section 121(d)(1) requires that Superfund remedial actions attain "a degree of cleanup of
hazardous substance, pollutants, and contaminants released into the environment and of control of
further release at a minimum which assures protection of human health and the environment." The
remedial action must achieve a level of cleanup that at least attains those requirements that are legally
applicable or relevant and appropriate. In performing the FYR for compliance with ARARs, only those
ARARs that address the protectiveness of the remedy are reviewed.
• Applicable requirements are those cleanup standards, standards of control, and other substantive
requirements, criteria or limitations promulgated under federal environmental or state
environmental or facility siting laws that specifically address a hazardous substance, remedial
action, location or other circumstance found at a CERCLA site.
• Relevant and appropriate requirements are those standards that, while not "applicable," address
problems or situations sufficiently similar to those encountered at the CERCLA site that their use
is well suited to the particular site. Only those state standards that are more stringent than federal
requirements may be applicable or relevant and appropriate.
• To-Be-Considered (TBC) criteria are non-promulgated advisories and guidance that are not
legally binding, but should be considered in determining the necessary remedial action. For
example, TBCs may be particularly useful in determining health-based levels where no ARARs
exist or in developing the appropriate method for conducting a remedial action.
Chemical-specific ARARs are health- or risk-based numerical values or methodologies which, when
applied to site-specific conditions, result in the establishment of numerical values. These values
establish an acceptable amount or concentration of a chemical that may remain in, or be discharged to,
the ambient environment. Examples of chemical specific ARARs include maximum contaminant levels
(MCLs) under the federal Safe Drinking Water Act and ambient water quality criteria enumerated under
the federal Clean Water Act.
Action-specific ARARs are technology- or activity-based requirements or limits on actions taken with
respect to a particular hazardous substance. These requirements are triggered by a remedial activity,
such as discharge of contaminated groundwater or in-situ remediation.
Location-specific ARARs are restrictions on hazardous substances or the conduct of the response
activities solely based on their location in a special geographic area. Examples include restrictions on
activities in wetlands, sensitive habitats and historic places.
-1
-------
Remedial actions are required to comply with the chemical-specific ARARs identified in the ROD. In
performing the five-year review for compliance with ARARs, only those ARARs that address the
protectiveness of the remedy are reviewed.
Groundwater ARARs
According to the 1995 ROD, The Remedial Action Objective (RAO) for groundwater remediation at the
Site is to prevent human exposure, via any exposure route [ingestion and non-ingestion (i.e., showering)]
to groundwater containing contaminants in concentrations that exceed ARARs and appropriate risk
levels.
Table F-l - ARAR Review for Groundwater
Contaminant of
1995 RI ARAR
Current 2018 ARAR
ARAR Change
Concern8
(hs/L)
(ns/L)b
Benzene
5b
5
No Change
2-Methylnaphthalene
NAC
NA
NA
Naphthalene
NA°
NA
NA
Beryllium
4b
4
No Change
Chromium (VI)
100d
100d
No Change
Manganese
200e
NAf
NA
Notes:
a-COCs from 1995 ROD.
b - Based on federal MCL.
c - ARAR not identified in ROD. Cleanup goal based on risk,
d - MCL for total chromium,
e - Based on MCL goal.
f- Manganese has no MCL, and therefore has no current ARAR.
Soil ARARs
The Site's 1993 Remedial Investigation Report stated that no chemical-specific ARARs existed for
constituents detected in soil. Action-specific soil ARARs specified in the 1995 ROD were relevant
during the remedy's construction, but are not relevant to the remedy's continued protectiveness. The
EPA calculated cleanup goals for soil COCs based on protection of ecological receptors.
-2
-------
APPENDIX G - TOXICITY REVIEW
Table G-l: Toxicity Review Table
Contaminant
Carcinogenic toxicity changes
Non-carcinogenic toxicity changes
Oral Cancer Slope Factor
Oral Reference Dose (RfD)
1993 RI/FS
Oral Cancer
Slope Factor
(mg/kg-day)-1
2018
Oral
Cancer Slope
Factor
(mg/kg-day)-1
Change in
Oral Cancer
Slope Factor
1993 RI/FS Oral
RfD Value
(mg/kg-d)
2018 Oral RfD Value
(mg/kg-d)
Change in
Oral RID
2-Methylnaphthalenec
c
N/A
N/A
c
4.0E-03
New
Arsenic
1.8E+00
1.5E+00
Lower
3.0E-04
3.0E-04
None
Benzene0
c
5.5E-02
New
c
4.0E-03
New
Beryllium
8.4E+00
N/A
N/A
5.0E-03
2.0E-03
Lower
Chromium (VI)d
c
5.0E-0P
New
c
3.0E-03
New
Nickel"-'
c
N/A
N/A
c
2.0E-02
New
Manganese6
N/A
N/A
N/A
1.10E-04
2.4E-02
Higher
Naphthalene0
c
N/A
N/A
c
2.0E-02
New
Notes
N/A = toxicity value not available for this substance,
a - Contaminant information based on nickel soluble salts RSL values,
b - Contaminant information based on non-diet RSL values.
c - COC identified in the Baseline Risk Assessment in the 1995 ROD; however, COC-related toxicity information not mentioned in 1993
RJ/FS.
d - The ROD lists Chromium (VI) as a COC; however, the 1993 Rl/FS only lists toxicity information for total chromium.
e - Based on toxicological information reviewed by the New Jersey Department of Environmental Protection, which classifies hexavalent chromium as a
carcinogen through oral exposure. The EPA is currently undergoing a review of the draft toxicological assessment for hexavalent chromium.
-------
APPENDIX H - INSTITUTIONAL CONTROL DOCUMENTS
-------
«ook17B6p«i879
*i I :tj
STATE Ol; SOUTH CAROLINA ) RESTRICTIVE COVENANTS AND SC
) CONDITIONS - 1.377 ACRE SITE
COUNTY OF; GREENVILLE ) PLAT BOOK 11-X, P/^OE fr:i> A ii: 2">
DEED BOOK 1248, PAGE 837
_ J v (¦'.; iiX
¦ * r i cr.cj
WHEREAS, Wilson Sporting Goods Co.. a Delaware corporation, is the owner and holder
of record title to that certain piece, parcel or lot of land containing approximately 1.377 acres, situate.
lying and being in the County of Greenville, State of South Carolina, as described in Exhibit A,
attached hereto and incorporated herein by reference as if fully set forth; and
WHEREAS, a release of hazardous substances, as defined by the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980,42 U.S.C. § 9601 et. Seq., has
occurred on the property described herein (hereinafter referred to as the "Property"); and
WHEREAS, the undersigned owner now wishes to acknowledge and place upon said
Property certain restrictions and conditions relative to the future use or development of said Property.
NOW, THEREFORE, in consideration of the Premises, the undersigned owner, for itself, its
successors and assigns, does hereby subject the Property described in Exhibit A to the following
restrictions and conditions ("Restrictions") relative to the use and development thereof, which
Restrictions shall run with the Property and shall be binding upon all owners or occupants thereof:
1. Use of the Property in any manner: (a) which would impair Wilson Sporting Goods
Co.. El Paso Natural Gas Company, Collins & Aikman Products Co., PepsiCo Inc., or Continental
Assurance Co. (hereinafter referred to as "Beaunit Lagoon Site PRP's"). and their authorized
representatives' entry to the Property: (b) which would impair the right of access granted to the
United States Environmental Protection Agency (hereinafter referred to as "EPA"), the State of
South Carolina and their authorized representatives: (c) which would interfere with the performance
. ?tC ftt 1U.00
of the work required by the consent decree in United Sta[«\Ko[^t^r{fif^\iCollins <£• Aikman
75785
-------
mok1786mci85W
Products C 'o. el ai. Civil Action No. 6-96-2659-21, United States District Court for the District of
South Carolina (hcreinaAer referred to as the "Consent Decree"), including operation and
maintenance and oversight; or (d) any activity which would disturb the integrity and effectiveness
of the cap: or (e) seeking the issuance or the issuance of any well installation permits that may
impact the Site during the duration of the remedial design/remedial actions, including operation and
maintenance, on the Property, without prior consultation by the State with EPA is prohibited, unless
the EPA Regional Administrator determines that the disturbance is (i) necessary to the proposed use
of the Property, and will not increase the potential hazard to human health or the environment, or (ii)
is necessary to reduce a threat to human health or the environment.
2. During the performance of the work required by the above referenced Consent
Decree, no potable water supply wells shall be installed at the Property within contaminated
groundwater or in areas which could draw from contaminated groundwater, except as authorized by
EPA.
3. Any subsequent transferees (a) shall permit the United States. EPA, the Stale of South
Carolina, Beaunit Lagoon Site PRP's, and their respective contractors and other authorized
representatives, to enter the Property to perform any work under the Consent Decree, including
oversight, and for any other purpose set forth in Section IX of the Consent Decree and to perform
operation and maintenance; (b) shall agree not to interfere with or disturb the performance of any
work pursuant to the Consent Decree, including oversight; and (c) shall agree to inform any person
that subsequently acquires any title, ownership, leasehold, easement, orother interest in the Property,
or any portion thereof, or any appurtenances thereto, of the requirements, conditions, and operative
effect of the Consent Decree.
-------
book1786p«iN81
4. The Property is the subject of the Consent Decree referenced above which was
recorded in the RMC Office of Greenville County. South Carolina, on May 14.1997 in Deed Hook
1689 at Page 666. ct seq. The restrictions and obligations set forth in Section IX. Paragraphs 24.25.
26 and 27 shall run with the land and shall be binding upon any and all persons, as defined in the
Consent Decree, and their successors and assigns who now or may hereafter acquire any title,
ownership, leasehold, casement, or other interest in the Property, or any portion thereof, or any
appurtenance thereto, in accordance with applicable South Carolina law.
IN WITNESS WHEREOF, the undersigned Corporation, by its duly authorized officers, has
hereunto set its hand and seal this 3! a-rday of August: 1998.
SIGNED, sealed and delivered in the
presence of the following w itnesses:
'.'.tu' \
.... V. IJ
\ •> i '!<»:<. 'IV'tQ li'i
#ICCC'*4»<
STATE OF J.LLiNCt S
WILSON SPORTING GOODS CO., a Delaware
corporation (SEAL)
By: V W- ¦ i.-~ ~ • -"
Print Name: /> /--i.
Its: Q c < ¦) t <¦ v *^71 -f.'c . * ,
ACKNOWLEDGMENT
COUNTY OF COOK-
Before me personally appeared ftx/t/jS to me well known, w ho,
being by me duly swom, did depose and say that (s)he is the (-* (#* •!$?/ of
Wilson Sporting Goods Co.. a Delaware corporation, and. as such, executed the foregoing
instrument, and that the seal affixed to the foregoing instrument is the Corporate seal of said
corporation and that it was affixed to said instrument by due and regular Corporate authority, and
that said instrument is the free act and deed of said corporation.
"OFFICIAL SEAL"
Kathleen A. Gable
Nutaiy I'uNIc, State of Itlir.oi®
My Commission Exp. (¥)ij
[MERE AFFIX THE SEAL OF
THE NOTARY PUBLIC)
aunt,-
Notary Public for
Mv Commission I
v//i V A ev
rfyS (SEAL)
-------
BOOK 17&6na$82
EXHIBIT A
DESCRIPTION OF PROPERTY
ALL that certain piece, parcel or tract of land, with any and all improvements
thereon, situate, lying and being northwest of Georgia Road, near the Town of
Fountain Inn in Greenville County, South Carolina, and having, according to a plat
entitled "Wilson Sporting Goods and Pepsico Property", prepared by James D.
Crain, R.L.S., dated July 26, 1985 and recorded in Plat Book 11-X at Page 9 in
the RMC Office for Greenville County, the following metes and bounds, to-wit:
BEGINNING at an iron pin located at the southwest corner of the subject property,
which pin is located within the right-of-way of Duke Power Company, and running
thence N 58-36 E 200 feet to an iron pin; thence N 31-24 W 300 feet to an iron
pin; thence S 58-36 W 200 feet to an iron pin; thence S 31-24 E 300 feet to an iron
pin, the point of BEGINNING.
FILED FOB RECORD IN GREENVILLE
COUNTY SC R O D. OFFICE AT 11:23 AM
09/09/98 RECORDED IN DEED
BOOK 1766 PAGE 0879
DOC o 98075785
-------
STATE OF SOUTH CAROLINA
COUNTY OF GREENVILLE
THIS DECLARATION OF COVENANTS AND RESTRICTIONS ("Declaration) is
made and altered into this ffffk day of 2010, by Cross Country Development LLC
("CCD") and the South Carolina Department of Health and Environmental Control
("Department").
RECITALS
WHEREAS, tins Declaration is altered into pursuant to S.C. Code §44-56-200 et seq.;
and
WHEREAS, CCD is the owner of certain parcels or lots of land described as Tracts B
and C-2, containing 0.136 and 1.823 acres respectively, in the County of Greenville, South
Carolina, as more particularly described in Exhibit A attached hereto and incorporated herein by
reference as if fully set forth (property referred to hereafter as the "CCD Property"); and
WHEREAS, a release of hazardous substances, as defined by the Comprehensive
Environmental Response, Compensation and Liability Act of 1980, 42 USC § 9601 et seq.
("CERCLA") has occurred on an adjacent property, which release is the subject of a Consent
Decree in United States of America v. Collins & Aikman Products Co. et al., Civil Action No. 6-
96-2659-21, United States District Court fin: the District of South Carolina, that was recorded in
the Office of the Recorder of Deeds for Greenville County South Carolina, on May 14,1997 in
Deed Book 1689 at Page 666, et seq.("Consent Decree"); and
WHEREAS, groundwater under the CCD Property contains benzene, a hazardous
substance as defined by CERCLA; and
WHEREAS, the Beaunit Lagoon Site Group ("BLSG") representing the respondents to
tiie above referenced Consent Decree (Le. Collins & Aikman Products Co., Wilson Sporting
Goods Company, and El Paso Natural Gas Company), at the directum of the United States
Environmental Protection Agency ("EPA") and for the purpose of protecting public health and
the environment, have requested CCD to place certain restrictions and conditions relative to the
future use and development of the CCD Property; and
WHEREAS, CCD has agreed to impose certain re&rictions on the manner io which the
CCD Property may be developed and used in the future; and
WHEREAS, it is the intention of all parties that EPA is a third party beneficiary of said
restrictions and said restrictions be enforceable by the EPA, Department, and then-
successor agencies; and
M1M45954 ffL
Book:0E 2374 Page:56IB-5623
July 08, 2010 02:06:05 Pfl
Ree:$14.00 Cnty Tax:$0.00 State Tax:$0.00
FILED IN GREENVILLE COUNTY.SC
)
) DECLARATION OF COVENANTS
) AND RESTRICTIONS
-------
• 2374 PAGE: 5617
WHEREAS, EPA has worked closely with the Department in developing the Consent
Decree, and EPA will assist the Department in monitoring and enforcing this Declaration; and
NOW, THEREFORE, KNOW ALL MEN BY THESE PRESENTS that CCD hereby
declares and covenants on behalf of itself, its heirs, successors, and assigns that the CCD
Property described in Exhibit A shall be held, mortgaged, transferred, sold, conveyed, leased,
occupied, and used subject to the following restrictions, which shall touch and concern and run
with the title to the CCD Property.
1. CCD covenants for itself, its heirs, successors and assigns that the CCD Property
shall not be used for the following purposes without prior written approval from EPA
and the Department or their successor agencies: residential, agricultural, child day
care facilities, schools, or elderly care facilities.
2. CCD covenants for itself, its heirs, successors and assigns that groundwater beneath
the CCD Property shall not be used for consumptive use or other purposes without
prior written approval from EPA and the Department or their successor agencies
3. CCD covenants for itself, its heirs, successors and assigns that there shall be no
drilling of groundwater wells on the CCD Property without prior written approval
from EPA and the Department or their successor agencies.
4. CCD covenants for itself, its heirs, and successors and assigns that the CCD Property
shall not be used for mining, extraction of coal, oil, gas or any other minerals or non-
mineral substances.
5. CCD covenants for itself, its heirs, successors and assigns that the EPA, the
Department, their successor agencies, and all other parties performing response
actions under EPA's or the Department's oversight shall be provided reasonable
access for (i) inspecting the CCD Property, (ii) monitoring, (iii) verifying
information, (iv) sampling the CCD Property, (v) assessing the need for additional
response or quality control practices, (vi) implementing the work required under the
Consent Decree (vii) assessing the responsible party's compliance, (viii) assessing
compliance with existing land use restrictions under the Consent Decree and this
Declaration, or (ix) taking such samples as may be necessary to enforce this
Declaration.
6. The covenants and restrictions set forth herein shall run with die title to the CCD
Property and shall be binding upon CCD, its heirs, successors and assigns. It is
expressly agreed that the Department and EPA shall have the right to enforce these
covenants and restrictions upon, CCD and its heirs, successors and assigns. CCD and
its heirs, successors, and assigns shall include the following notice on all deeds,
mortgages, plats, or any legal instruments used to convey any interest in the CCD
Property (failure to comply with this paragraph does not impair the validity or
enforceability of these covenants):
Page 2 of7
-------
NOTICE: This Property Subject to Declaration of Covenants and
Restrictions and any subsequent Amendments Recorded at
7. This Declaration shall remain in place until such time as the Department has made a
written determination that the covenants and restrictions set forth herein are no
longer necessary. The Department shall not consent to any such termination unless
the requirements of the Consent Decree have been met This Declaration shall not be
amended without the written consent of the Department or its successor agency. The
Department shall not consent to any such amendment or termination without the
consent of EPA.
11. It is expressly agreed that EPA is not the recipient of a real property interest but is a
third party beneficiary of the Declaration of Covenants and Restrictions and, as such,
has the rights of enforcement
12. This Declaration only applies to the CCD Property expressly identified in Exhibit A
and does not impair the Department's and EPA's authority with respect to the CCD
Property or other real property under the control of CCD.
IN WITNESS WHEREOF, CCD has caused this instrument to be executed as of the
date first above written.
CROSS COUNTRY DEVELOPMENT, LLC
Page 3 of7
-------
STATE OF ILLINOIS)
COUNTY OF COOK ) ACKNOWLEDGEMENT
I, Mary Parrott Downing (Notary Public), do hereby certify that Ray M. Berens, an
authorized representative of CCD, personally appeared before me this day and acknowledged the
due execution of the foregoing instrument, on behalf of CCD.
Witness my hand and official seal this day of Qui / 2010.
Page 4 of7
-------
STATE OF
COUNTY OF
TomnJ
J
klaf\Ai&
J ACKNOWLEDGEMENT
(Notary Public), do hereby certify that Marcus R.
Ferries, an authorized representative of CCD, personally appeared before me this day and
acknowledged the due execution of the foregoing instrument, on behalf of CCD.
Witness my hand and official seal this
day of2010.
MONICA HAYES
AMMNBIWn BM
APra.tt.aoia
GfliUi.
Public for
£&a-h. Tom a J
My Commission Expires: flfjjh/ I0-. CtOfl
Page 5 of7
-------
BOOK: 2374 PAGE: 5621
IN WITNESS WHEREOF, the Department has caused this instrument to be executed as
of the date first above written.
WITNESSES
South Carolina Department of Health
and Environmental Control
By: £).
Daphne G. Neel, Chief
Bureau of Land and Waste Management
South Carolina Department of Health and
Environmental Control
STATE OF SOUTH CAROLINA
COUNTY OF RICHLAND
ACKNOWLEDGEMENT
)
Ot AtJt (Notary Public), do hereby certify that
Daphne G. Neel, Chief, Bureau of Land and Waste Management, personally appeared before me
this day and acknowledged the due execution of the foregoing instrument.
Witness my hand and official seal this day of . 2010.
Notary Public forffll/ffi/- tt i
My Commission
/n? "i. #. fr.y,
:
• : ,*C * ' ' - -r
4J-
Page 6 of7
• ' v 9
: t J • ,
• v.A ° ^ Ji- r-~-
-mm
-------
BOOK: 2374 PAGE: 9622
EXHIBIT A
DESCRIPTION OF PROPERTY SUBJECT TO THE FOREGOING RESTRICTIVE
COVENANTS AND CONDITIONS
PROPERTY DESCRIPTION
TRACT "B"
ALL that certain piece, parcel or tract of land lying and being situate near the City of
Fountain Inn, County of Greenville, State of South Carolina and being described more
particularly below to wit:
COMMENCING at a nail (set) located at the intersection of the centerline of Valley View Road
and the centerline of S.C.L. Railroad, thence with said centerline (more or less) of Valley View
Road N 16 35 42 E for 1490.32 feet to a W rebar (set) being the true POINT OF BEGINNING,
thence continuing along said centerline N 16 35 42 E for 119.81 feet to an iron pin (found),
thence leaving said centerline S 66 36 54 E for 99.62 feet to a %" crimp top iron pin (found),
thence S 59 04 28 W for 83.97 feet (passing through a reference Vi" rebar (found) at 73.97 feet)
to a'/»" crimp top iron pin (found), thence S 59 04 28 W for 62.51 feet to a Vt" rebar (set) being
the point of beginning. Said tract contains 0.136 acres.
PROPERTY DESCRIPTION
TRACT "C-2"
ALL that certain piece, parcel or tract of land lying and being situate near the City of Fountain
Inn, County of Greenville, State of South Carolina and being described more particularly below
to wit:
COMMENCING at a nail (set) located at the intersection of the centerline of Valley View Road
and the centerline of S.C.L. Railroad, thence with said centerline (more or less) of Valley View
Road N 16 35 42 E for 1490.32 feet to a '/a" rebar (set), thence N 16 35 42 E for 119.81 feet to an
iron pin (found) being the true POINT OF BEGINNING, thence N 17 56 23 E for 231.77 feet to
a Vi" rebar (set), thence S 71 13 03 E for 409.03 feet to a bent W open top iron pin (found),
thence S 29 29 19 W for 264.76 feet to a Vi" crimp top iron pin (found), thence N 32 48 49 W for
209.59 feet to a point, thence S 59 01 11 W for 143.81 feet to a V" crimp top iron pin (found),
thence N 66 36 54 W for 99.62 feet to an iron pin (found) being the point of beginning. Said
tract contains 1.823 acres.
Page 7 of 7
-------
BOOK: 2374 PAGE. 9623
TRACT B
167.80'
LINE TA
BLE
LINE
LENGTH
BEARING
L1
105.63
S71 *02'30"E
L2
119.81
N16*35'42"E
L3
99.62
S66'36'54"E
L4CT0T)
83.97
S59*04'28"W
L5
62.51
S59'04'28"W
L6
309.69
S30'52'33"E
L7
109.44
nssio'so-e
L8
128.81
N58*54*11"E
L9
100.22
N32"48'49"W
L10
46.47
S66*40'42"E
L11
19.88
N72*44'52"E
TRACT C-1
199,050 SF*
4.570 AC.*
TMS # "
0338000100400
EXCERPTS FROM "SURVEY FOR CROSS COUNTRY
DEVELOPMENT, LLC", DATED SEPTEMBER 10,
2010,PREPARED BY C.O. RIDDLE SURVEYING
C0" IrFID FOR RECORD IN CffiEKVULE COWTf.SC ROD
2010645954 Book:DE 2374 Page:5616-5623
July 08, ,2010 02:08:08 Pfl
EXHWT(
------- |